COMPLAINT FOR INJUNCTIVE RELIEF

1. This is an action under the Freedom of Information Act
("FOIA"), 5 U.S.C. ¤ 552, for injunctive and other appropriate relief and
seeking the disclosure and release of agency records improperly withheld
from plaintiff by defendant United States Secret Service.

Jurisdiction and Venue

2. This court has both subject matter jurisdiction over this
action and personal jurisdiction over the parties pursuant to 5 U.S.C. ¤
552(a)(4)(B). This court also has jurisdiction over this action pursuant
to 28 U.S.C. ¤ 1331. Venue lies in this district under 5 U.S.C. ¤
552(a)(4)(B).

The Parties

3. Plaintiff Computer Professionals for Social Responsibility is
a non-profit membership organization, incorporated in the state of
California, with an office and full-time staff in Washington, DC.
Plaintiff's membership includes a Nobel Laureate and four recipients of
the Turing Award, the highest honor in computer science. Plaintiff's
activities include the review of federal computing policies to determine
their possible impact on civil liberties interests. Among its other
activities, plaintiff has prepared reports and presented testimony on
computer technology issues at the request of congressional committees.
In pursuit of its mission, plaintiff has submitted several requests to
defendant Secret Service under the FOIA seeking information concerning
the agency's exercise of its jurisdiction to investigate computer crime.
4. Defendant United States Secret Service is an establishment
within the Department of the Treasury. The Secret Service is an agency
within the meaning of 5 U.S.C. ¤ 552(e). The Secret Service has primary
federal jurisdiction over the investigation of computer crime.

The Documents at Issue and Plaintiff's FOIA Request

5. On November 6, 1992, a group of individuals affiliated with 2600
Magazine assembled in the public food court area of the Pentagon City
Mall in Arlington, Virginia. 2600 Magazine contains articles and letters
from its readers concerning computer and telecommunications technology
and related issues. The magazine has published articles of public
interest since 1984. The magazine publicizes monthly gatherings around
the country to enable its readers to meet one another, socialize and
exchange information of mutual interest.

6. Soon after the group had assembled, it was confronted by mall
security personnel, officers of the Arlington County Police and other
unidentified individuals. The group members were ordered to provide
identification and their names were recorded by mall security personnel.
Several of the group members were ordered to submit to searches of their
personal property, some of which was seized by mall security personnel
and not returned for several days. The group members were finally
ordered to disperse and leave the premises of the mall.

7. During the course of the aforementioned search, membership
materials of plaintiff organization, CPSR, were seized.

8. According to a mall security official and representatives of the
Arlington County Police, agents of defendant Secret Service were present
during the incident and had directed the activities of the mall security
personnel. The presence and involvement of Secret Service agents were
reported in the media several days after the incident.

9. By letter to defendant Secret Service dated November 10, 1992,
plaintiff requested copies of all agency records "pertaining to the
breakup of a meeting of individuals affiliated with '2600 Magazine' at
the Pentagon City Mall in Arlington, Virginia, on November 6, 1992."

10. By letter to plaintiff dated December 9, 1992 (but received by
plaintiff on December 22, 1992), defendant Secret Service asserted that
it would "neither confirm nor deny the existence of investigatory
information pertaining to the individuals" referenced in plaintiff's
request unless plaintiff provided "properly notarized releases" from the
individuals. Defendant further stated that the letter "is not a denial of
[plaintiff's] request," and that "[u]pon receipt of a perfected request,
a search of files will be conducted."

11. By letter to defendant Secret Service dated December 22, 1992,
plaintiff noted that its request did not seek "information identifying
particular individuals," but rather "the disclosure of information
concerning the Secret Service's involvement in an incident that has been
widely publicized in [the] media." Plaintiff further noted that, to the
extent that the requested information contains references to particular
individuals, "the agency might be entitled to invoke [FOIA exemptions] to
protect the privacy of those individuals." Finally, plaintiff requested
that its letter be treated as an administrative appeal if "the Secret
Service does not intend to process [plaintiff's] request as submitted."

12. By letter to plaintiff dated January 7, 1993, defendant Secret
Service stated that "[a] search of files responsive to [plaintiff's]
request is being conducted" and advised plaintiff that "[w]hen the
results of the search are known, you will be contacted."

13. To date, defendant Secret Service has not released any
information responsive to plaintiff's request.

14. Plaintiff has exhausted the applicable administrative
remedies.

15. Defendant Secret Service has wrongfully withheld the
requested records from plaintiff.

Requested Relief

WHEREFORE, plaintiff prays that this Court:

A. order defendant Secret Service to disclose the requested
records in their entirety and make copies available to plaintiff;
B. provide for expeditious proceedings in this action;
C. award plaintiff its costs and reasonable attorneys fees
incurred in this action; and
D. grant such other relief as the Court may deem just and proper.